Personal Data collected by automated means

When you visit our Websites or use our Services, subject to your prior consent where applicable by law, we may collect personal data without you actively submitting such information, by automated means, using technologies such as cookies, web server logs, web beacons, and similar technologies as described below.

The types of personal data that we may collect through your visits to the Websites or use of the Services include, to the extent permitted under applicable law and, where required, subject to your express consent, are:

• the date and time of visit, referring address (location from which a visitor comes to the Websites);
• type of Internet browser, OS and device details; 
• visitor’s IP address (a unique number that is assigned to any computer that connects to the Internet for identification purposes); 
• traffic data for calls or Internet session when you use our phone or Internet services, including called numbers, identification of the phone, duration of the call, date, duration and data volume of the Internet session; 
• as the case may arise location data generated during calls or Internet sessions; 
• as the case may arise location data generated during calls or Internet sessions; 

How do we use your personal data: 

QKT shall only process your personal data for the purposes described in this Privacy Policy or as otherwise permitted under applicable law. The processing of your personal data by QKT for the purposes described hereunder is based on your explicit consent or on the necessity to process your personal data for the purposes of our legitimate interests 

Your personal information may be processed, both by QKT and its affiliates, for purposes including: 

• administer our relationship with you, including to respond to your inquiries or complaints; 
• to provide any goods, Services or information you have requested and information about our products and Services; 
• to administer, operate, maintain, and improve the Websites and our Services; 
• for efficient customer management relationship;
• to simplify access to some interactive features on our Websites or Services; 
• to manage your accounts, orders, invoices and payments; 
• to manage and provide after-sale services; 
• to administer accounting and taxes; 
• to respond to requests from administrative or judicial authorities; and 
• to comply with applicable laws and regulations. 

Providing personal data for these purposes is necessary and refusal would make it impossible for QKT to manage the Contract with you or to comply with its contractual and legal obligations. Subject to your consent where required by law, we may also use your personal data in order: 

• to keep improving the way our website works. 
• to count how many persons visit our websites, where they come from, when they visit, how long they stay and what pages they look at. 
• to associate your activity on our website in order to give us insights into products and services you might like and measure how our advertising performs 
• to note browser, OS and device details used to make sure you get a good online experience when you access our websites. 
• to provide you access to valuable QKT internet-based information and Services; 
• to audit usage of the Websites; 
• to market and improve the Services that we offer; and 
• to conduct promotions campaigns, survey and other marketing initiatives pursuant to the “How do we use your personal data for marketing purposes?” section to follow. 
• Let you know about other offers and discounts 
• Understand how you use products & services to develop newer & better versions 
• Carry out research and statistical analysis including to monitor how all customers use our network, products and services on an anonymous or business by business basis 
• Prevent and detect fraud or other crimes, recover debts or trace those who owe us money 
• Providing personal data for marketing purposes is optional and refusal will have no consequence on the performance of any Contract by QKT. 

In addition, we collect information from visitors to our websites to help us to make improvements to the websites and to the Services we make available. We know, for instance, how many visitors there are to each website page, when they visited, for how long and to which areas of the website. We may share this information with our advertisers and to other companies that offer their goods or services on our websites. It helps us to show these organisations how effective our website is as a sales channel for products. You or any other individual cannot be identified from the information we share as the data is aggregated and anonymised. 

Why and with whom do we share your personal data? 

Our policy is to not give, sell or otherwise distribute personal data we collect to third parties outside of QKT, except where required with your express consent or where this is necessary and in accordance with applicable law. In line with this, we share personal data with the recipients listed below. 

QKT subsidiaries and affiliated entities (‘QKT Affiliates’). We may share your personal data with other companies of the QKT Group (a list of QKT Affiliates is available at https://www.QKT.net/legal/ and then selecting the option QKT Group of Companies. 

For the purposes specified under the “How do we use this information?” section previous and as described under the “Will Personal Data be transferred abroad?” section in this document.

Third party service providers. Your personal data may be disclosed to third party service providers, acting on our behalf, in connection with managing services, data analytics, finance, accounting or other administrative services and information technology support. These third party service providers will have access to – and process – personal data only on our behalf and under our instructions and will be held to appropriate security obligations. 

QKT’s business partners. A list of such partners could be provided to Customers upon request provided there is a legitimate reason. 

Other data recipients. For the above purposes or where otherwise required by law, we may also need to make personal data available to third parties such as advisors, banks and financial institutions, professionals, independent consultants, potential or existing investors and/or acquirers (in connection with a merger, acquisition, or sale involving QKT or its affiliates or as part of a corporate reorganization, stock or asset sale, or other change in corporate control), regulatory and/or administrative authorities, courts, police authorities 

QKT may provide information, in response to properly made requests, for the purposes of the prevention and detection of crime, and the apprehension or prosecution of offenders, when required to do so by law, for example under a court order, or in response to properly made court or administrative demands. QKT may also provide information for the purpose of safeguarding national security. In either case, QKT will act in accordance with applicable Data Protection Law. 

Other telecommunications operators. QKT receives information from other telecommunications operators about their customers to enable QKT to enter their details (together with our own customer´s information) in telephone directories. We also make telephone numbers available on directory enquiry services unless customers (BT or other licensed telecommunications operators) have chosen to be ex-directory. 

We may also disclose personal data about you when you explicitly consent (via contract or other legal instrument) to such transfer or when we believe disclosure is necessary or appropriate for our legitimate interests (or those of the third party to whom we disclose your data), provided that they are not overridden by the data subject’s interests or fundamental rights and freedoms, in accordance with applicable laws. 

How is your personal data protected? 

QKT has appropriate policies and technical and organizational measures in place to safeguard and protect your personal data against unlawful or unauthorised access, accidental loss or destruction, damage, unlawful or unauthorised use and disclosure. We will also take all reasonable precautions to ensure that our staff and employees who have access to personal data about you have received adequate training. 

How can you update or delete your personal data?  

In accordance with applicable data protection laws, you have the right to access personal data we hold about you and request the rectification or erasure of any inaccurate data. You may exercise such rights by contacting us as described under the ” What are your data subject rights?” clause mentioned. 

When you register online for a QKT account, you can also view and update your personal data by logging onto the Website and following the relevant instructions. To ensure any details we hold about you remain accurate, please update your personal data if it changes or send a request to us as described under the “What are your data subject rights?” clause mentioned. If you close your account we may, for limited periods and in accordance with applicable law, retain some personal data in order to comply with legal obligations or for other proper purposes, such as legal retention obligations, collecting outstanding debts or resolving legal disputes. 

How do we use your personal data for monitoring and recording of calls? 

Your telephone calls to us may be recorded for the purposes of staff training and service quality, as well as evidence of a commercial transaction, subject to applicable law. You will be informed about this in a recorded message before your call is put through to a member of staff. Calls that are recorded for these purposes will be kept secure, will not be disclosed outside our group of companies, other than for operational purposes, and will be deleted in accordance with our policies and relevant legal requirements. 

Data processing complaints 

Should you wish to raise a complaint about your personal data, please download the form below and once completed, send it to (Email ID) together with a document that can identify you. 

Lawfulness,fairness,transparency 

QKT must process personal data in accordance with the following:  

(a) Lawfulness: the processing of personal data must be justified on a lawful basis 

(b) Fairness: personal data must be processed fairly in ways that would be reasonably expected. 

(c) Transparency: information must be provided about the processing in a clear, precise and unambiguous way. 

Purpose Limitation: 

QKT must ensure that personal data is processed only for the specific, explicit and legitimate purposes for which it was gathered and not further processed in a way which is incompatible with the purpose for collection. 

Data Minimisation: 

Personal data collected must be adequate, relevant and be limited to the purposes for which it is processed. 

Storage Limitation: 

QKT must store personal data allowing identification of the individual for no longer than is necessary in accordance with the purpose of its collection and processing. 

Accuracy: 

QKT must take reasonable steps to ensure that that personal data is accurate, complete and where necessary, kept up to date. 

Where QKT discovers that personal data is inaccurate or out of date all reasonable steps will be taken to correct or erase this data as soon as possible. 

Security  

QKT must ensure that the personal data that is collected and processed is protected by implementing appropriate technical and organisational measures to prevent unauthorised or unlawful data processing, accidental loss, destruction or damage. 

In particular, QKT must ensure that its employees who, in the performance of their duties, have access to personal data, undertake to treat such data as confidential and refrain from disclosing it to other parties, unless it is lawful to do so. 

Where there is a suspected (or confirmed) breach of security which involves accidental, unauthorised or unlawful access to, or disclosure, alteration, loss or deletion of any personal data by any QKT employee or any third party, please contact CSIRT in line with the Personal Data Incident Response Process. 

Data privacy by design and default 

QKT must apply measures to safeguard and demonstrate compliance with data protection legal requirements by designing and implementing data protection by design and by default:

(a) Privacy by design: When designing a product or service, from the outset the QKT must take into account issues such as information requirements or obtainment of appropriate consent to process customer personal data.

(b) Privacy by default: By default, only the personal data necessary to achieve the legal objective pursued must be processed, whilst ensuring confidentiality of personal data.

7.8.2 The Privacy Impact Assessment (PIA) is a useful tool for ensuring that privacy is built in to all new processing activities and so QKT has developed guidelines and templates for:

(a) When to conduct a PIA (see PIA Justification for details);

(b) How to complete a PIA (see PIA Completing Guide and FAQs); and

(c) A template PIA document.

7.8.3 QKT has established that a PIA must be undertaken in the following circumstances:

(a) Systematic and thorough evaluation of personal aspects relating to individuals, based on automated data processing, including profiling, and on which decisions about those natural persons are based.

(b) Large-scale data processing of sensitive data or data related to criminal convictions and offences. In QKT, large scale data processing is defined as 100 or more data subjects.

(c) Systematic monitoring of a publicly accessible area.

(d) Processing of sensitive personal data.

(e) Impact to a person’s privacy is significant or maximum. Please refer to the PIA guidance document for further examples of impact.

The QKT PIA methodology must be followed to assess and determine the privacy controls required for any business activity involving a privacy risk e.g. projects, procurement of goods and services.

Employees should refer to the above documentation when conducting a PIA or assessing if one is needed and should contact the QKT Data Protection team if required.

Accountability 

QKT as a data controller is responsible for how it processes personal data and complying with this policy.

All Employees are required to act in accordance with this policy and, where appropriate, ensure that it is enforced.

The Data Protection team is responsible for this policy and providing training on it, however many Employees will be required to fulfil parts of this policy, most notably the Individual Rights principle

Individual Rights

QKT shall inform all individuals about how to exercise their rights and ensure that individuals are able to exercise their rights freely. QKT will respond as appropriate to requests to exercise any of the following individual rights:

(a) Right of access: Individuals have the right to access a copy of the personal data that has been collected about them (whether held by QKT itself or at its providers), and be provided with information about the processing.

(b) Right of rectification: Individuals have the right to rectify any inaccurate or incomplete personal data concerning them (whether held by QKT itself or at its providers), in order to guarantee their accuracy and the appropriate processing thereof.

(c) Right of erasure (right to be forgotten): Individuals have the right to the deletion of personal data concerning them.

(d) Right to object: Individuals have the right to object to the processing of personal data at any time.

(e) Right of restriction: Individuals have the right to restrict the processing of personal data concerning him or her. This means that the processing will be “paused” and the personal data will only be stored.

(f) Right of data portability: Individuals have the right to receive personal data concerning them and to have that data transmitted to another controller in a structured, commonly used, machine-readable format.

(g) Right to non-automated data processing: Individuals have the right not to be subject to a decision affecting them, where this decision is based on automated data processing of information, including profiles. This includes cases in which QKT uses cookies as a technical tool to evaluate customers and predict their behaviour, performance or preferences, comparing their profile with that of other users or similar customers.